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International

  • December 14, 2018

    TCJA Could Spur Several Copycats, US Treasury Official Says

    Despite complaints about key international provisions of the U.S. tax overhaul, several countries have signaled interest in copying some of the measures, a senior official with the U.S. Department of the Treasury has said.

  • December 14, 2018

    Global Risk-Standard Unity Sought For Tax Rifts: IRS Official

    The U.S. and other countries participating in a pilot program on global tax dispute resolution are working toward common risk-assessment standards, but concede uniformity of data for multinational enterprises’ country-by-country reporting isn’t likely, an IRS official has said.

  • December 14, 2018

    Treasury To Re-Examine Obama Tax Rules On Debt In 2019

    The U.S. Department of the Treasury will reassess controversial Obama-era rules on tax avoidance through intercompany lending once the 2017 tax overhaul law’s international provisions are in place next year, a top-ranking official said Friday.

  • December 14, 2018

    No IRS Project On Guarantee Pricing, Treasury Official Says

    The U.S. Treasury Department and the Internal Revenue Service aren’t working on transfer pricing regulations that cover the pricing of guarantees in cross-border financing arrangements, a Treasury official said Friday in sharing the government’s current thinking.

  • December 14, 2018

    Nothing More On Services Transactions Under BEAT: Official

    Tax practitioners shouldn’t expect further concessions from the government on how the base erosion and anti-abuse tax applies to services transactions, a U.S. Department of the Treasury official said at an international tax conference Friday.

  • December 14, 2018

    Treasury Exploring Relief On Downward Attribution Question

    The U.S. Treasury has limited authority to address a provision in the U.S. tax overhaul that increased the number of entities classified as controlled foreign corporations, but may be able to offer relief in specific circumstances, an official has said.

  • December 14, 2018

    Taxation With Representation: Kirkland, Gibson Dunn

    In this week’s Taxation With Representation, Travelport is taken private in a $4.4 billion deal, Lexington Partners closes on a $1 billion capital commitment for TPG Asia funds, and Permira snags private universities from Laureate Education for €770 million. 

  • December 14, 2018

    Taxing GILTI Could Present Big Problems For States

    States seeking to include the federal tax overhaul’s new global intangible low-taxed income in their corporate income tax bases will be doing so in the face of significant policy and constitutional hurdles.

  • December 14, 2018

    EU Refuses To Reopen Brexit Deal, Putting Passage In Doubt

    The European Council has formally told the U.K. that its Brexit withdrawal agreement is not open to renegotiation even though a majority of British lawmakers rejected the package, increasing the odds of a no-deal departure from the bloc or a postponement.

  • December 13, 2018

    Australia Says Corporate Taxes Grew By $5.4B In 2016-2017

    Australia’s corporate taxes increased by AU$7.5 billion ($5.4 billion) for the 2016-2017 income year compared with the previous income year, according to a recent report by the Australian Taxation Office.

  • December 13, 2018

    Treasury Soon To Release Rules For Previously Taxed Income

    The U.S. Treasury Department will release preliminary guidance on the treatment of previously taxed income — foreign income already taxed by the IRS before the taxpayer brings it home — before the end of the year, an official said Thursday.

  • December 13, 2018

    Arent Fox Nabs Ex-Shearman Atty For DC Tax Practice

    Arent Fox has announced a former Shearman & Sterling LLP partner is joining the firm’s tax practice in Washington, D.C., to assist clients with domestic and international transactional tax issues.

  • December 13, 2018

    IRS Will Fight Transfer Pricing, Even If It Loses, Official Says

    The Internal Revenue Service will continue to litigate transfer pricing cases as a way to drive compliance regardless of how courts rule in the disputes, the agency’s top official said Thursday.

  • December 13, 2018

    Treasury Floats Rules On Withholding Payments Under FATCA

    The U.S. Department of the Treasury proposed regulations Thursday to eliminate or defer withholding taxes on certain payments out of America to foreign banks that have fallen short on their requirements under the Foreign Account Tax Compliance Act.

  • December 13, 2018

    Blockchain Threatens To Smash Tax System Into Pieces

    Blockchain and similar distributed accounting technologies could be at the verge of revolutionizing and decentralizing user-supported services, transforming the tax landscape and potentially giving tax administrations a serious headache.

  • December 13, 2018

    Proposed BEAT Rules Give A Break For Costs With Markups

    The U.S. Department of Treasury on Thursday proposed regulations that clear up ambiguities regarding the federal tax overhaul’s base erosion and anti-abuse provision, such as providing a break when intercompany costs have markups, but left terms under pre-existing law untouched.

  • December 13, 2018

    Treasury Wants Clear Rules For Foreign Sales Tax Benefit

    The U.S. Department of Treasury and the Internal Revenue Service will look to “bright line” rules in regulations to define which foreign sales qualify for a special tax benefit under the 2017 tax overhaul law, an IRS official said Thursday.

  • December 13, 2018

    2018 International Tax Policy: Year In Review

    The U.S. Department of Treasury has spent the past year attempting to interpret the federal tax overhaul’s complex international measures while a global debate over how to tax digital revenue simmered overseas. Here is a look back at six major tax policy developments in the U.S. and around the world.

  • December 13, 2018

    Swiss Celebrate Timely Resolution of 257 Tax Disputes

    Switzerland last year closed 87 disputes concerning transfer pricing, approved 60 tax rulings and resolved more than 100 miscellaneous double tax disagreements, meeting global norms by resolving complaints within an average two years, a government report published Thursday said.

  • December 13, 2018

    OMB Completes Review Of Proposed BEAT Regulations

    The Office of Management and Budget said Thursday it had concluded its review of proposed regulations for base erosion and anti-abuse taxes.

Featured Stories

  • Taxing GILTI Could Present Big Problems For States

    Maria Koklanaris

    States seeking to include the federal tax overhaul’s new global intangible low-taxed income in their corporate income tax bases will be doing so in the face of significant policy and constitutional hurdles.

  • Blockchain Threatens To Smash Tax System Into Pieces

    Alex M. Parker

    Blockchain and similar distributed accounting technologies could be at the verge of revolutionizing and decentralizing user-supported services, transforming the tax landscape and potentially giving tax administrations a serious headache.

  • 2018 International Tax Policy: Year In Review

    No Photo Available

    The U.S. Department of Treasury has spent the past year attempting to interpret the federal tax overhaul’s complex international measures while a global debate over how to tax digital revenue simmered overseas. Here is a look back at six major tax policy developments in the U.S. and around the world.

Expert Analysis

  • CFCs Hope For Only Intercompany Debt Per Section 163 Regs

    Lindsey Goble

    The IRS' Section 163(j) proposed regulations set out a complex process for determining the deductibility of an applicable controlled foreign corporation business interest expense. However, CFCs that have only intercompany debt can elect out of a Section 163(j) limitation, say Lewis Greenwald and Lindsey Goble of DLA Piper.

  • Few Taxpayers Should Use New Offshore Disclosure Protocol

    Patrick McCormick

    Last month, the IRS updated its voluntary disclosure practices. For taxpayers without criminal exposure, the updated protocol can provide the optimal route for an offshore disclosure, but more palatable options likely exist for the significant majority of noncompliant taxpayers, says Patrick McCormick of Drucker & Scaccetti.

  • Tax Reform Keeps Switzerland A Top Corporate Locale

    Danielle Wenger

    In this overview of the latest iteration of Swiss tax reform, Danielle Wenger and Manuel Vogler of Prager Dreifuss AG discuss key measures of the new reform and assess the impact for corporations.

  • Key Choices For Investors Under New Partnership Audit Rules

    Brad Wagner

    For 2018 returns, partnership tax audit adjustments will be assessed at the partnership — not the partner — level, causing a potentially inequitable result in the typical foreign blocker structure. The IRS has issued favorable, albeit complex, regulations to address this scenario, says Brad Wagner of Wagner Duys & Wood LLP.

  • Shifting Federal Policies Sow Discord In US Real Estate

    Eric Rapkin

    Changes in tariffs, tax law and bank deregulation present a confusing picture of short-term gains and long-term risk for real estate. Eric Rapkin of Akerman LLP takes a look at the industry's "winners" and "losers" following these developments.

  • 2018 Year-End Estate Planning: Part 4

    Diane Burks

    In the conclusion of their four-part estate planning series, Joshua Rubenstein and Diane Burks of Katten Muchin Rosenman LLP discuss implications of the Tax Cuts and Jobs Act relevant to international tax planning as well as state-specific considerations.

  • Foreign Tax Credit Guidance Provides Limited GILTI Relief

    Yomarie Habenicht

    Last week, the U.S. Department of the Treasury released over 300 pages of proposed foreign tax credit regulations providing partial relief for corporate taxpayers by limiting expenses allocated to the global intangible low-tax income basket, say attorneys from Proskauer Rose LLP.

  • Opinion

    Why We Need Anti-Money Laundering Whistleblower Awards

    Eric Havian

    The recent Mossack Fonseca indictments and Deutsche Bank raid would not have been possible without the whistleblower behind the Panama Papers leak. But there is no incentive for rooting out the type of criminal money laundering revealed here, creating a large enforcement gap, say Eric Havian and Michael Ronickher of Constantine Cannon LLP.

  • 5 Business Takeaways From The Midterms

    Mary Moore Hamrick

    Now that the midterms are over, business leaders have a little insight into the future of taxes, trade and other policy issues affecting the economy. Still, companies should remain agile as, come January, a new and divided Congress will begin to chart its course, says Mary Moore Hamrick of Grant Thornton LLP.

  • Proposed Section 956 Regs Benefit US Corporate Borrowers

    Anne Kim

    Per IRS guidance released last month, Section 956 should allow controlled foreign corporation subsidiaries of corporate U.S. borrowers to provide full credit support for a U.S. parent’s borrowing without suffering adverse tax consequences. However, the mechanics for applying this section to U.S. partnerships remain unclear, say attorneys at Proskauer Rose LLP.